This Privacy Policy explains how HabitationLuxe.com, operated by Splendaria Sàrl (“we”, “us”, “our”), collects and processes personal data when you use www.habitationluxe.com (the “Website”), contact us, or use our services. 

1) Controller (Who is responsible)

Controller: Splendaria Sàrl
Email: services@splendaria.com

2) What personal data we collect

Depending on how you interact with us, we may collect:

• Identity & contact data: name, email, phone number, postal address.
• Property-related data: address of the property, characteristics, documentation you provide (e.g., plans, photos), valuation inputs, listing preferences.
• Client and transaction data: information required to manage a brokerage mandate, viewings, offers, and contracts.
• Investor/professional data: company name, role, investment criteria, acquisition/disposal interests.
• Website & device data: IP address, device/browser information, usage data, pages visited, approximate location (from IP).
• Communications: messages you send us by forms, email, phone, or chat.

3) How we collect personal data

We collect data:

• directly from you (e.g., contact forms, emails, calls, meetings);
• from third parties you instruct (e.g., co-owners, representatives);
• from public sources or partners where permitted (e.g., public registers, portals, service providers);
• automatically via cookies and similar technologies (see Section 9).

4) Why we process personal data (purposes)

We process personal data to:

• respond to inquiries and provide requested information;
• perform property valuations and prepare marketing proposals;
• market properties (e.g., create listings, publish on portals, run campaigns);
• manage viewings, buyer screening, offers, and negotiations;
• perform contract and transaction administration;
• operate, secure, and improve the Website and our services;
• comply with legal obligations and enforce our rights.

5) Legal basis (GDPR where applicable)

Where the GDPR applies, we process your data based on one or more of:

• Contract / pre-contract steps (e.g., mandate, viewings, offers);
• Legitimate interests (e.g., marketing our services, Website security, fraud prevention);
• Consent (e.g., non-essential cookies, marketing communications where required);
• Legal obligations (e.g., compliance duties).

(Transparency expectations for privacy notices are reflected in GDPR Articles 13/14 guidance and EU Commission explanations.)

6) Marketing, listings, and media (photos/video/drone)

If you engage us to market a property, we may process and publish:

• photos, videos, drone footage, floor plans, descriptive texts, and property characteristics;
• location details necessary for marketing (usually address or approximate location, depending on your preference/market practice).

We publish such content only as required for marketing the property and according to the mandate/agreement with the seller.

7) Who we share personal data with

We may share personal data with:

• Service providers (processors): hosting, analytics, CRM, email services, photographers/videographers, marketing providers, IT support.
• Property portals and advertising platforms: for listing distribution and campaign delivery.
• Professional counterparts: notaries, banks/mortgage partners (if you request), lawyers, insurers, trustees, property managers (as needed for a transaction).
• Qualified buyers / sellers: limited information necessary to progress a viewing, offer, or transaction.
• Authorities: where required by law or to protect rights.

When we use processors, we require appropriate contractual safeguards. (Swiss law also recognizes processing via processors under legal conditions.)

8) International transfers

Your data may be processed in Switzerland, the EU/EEA, or other countries depending on the tools we use (e.g., cloud providers, portals, analytics). Where required, we implement appropriate safeguards (e.g., contractual protections) to protect your data.

9) Cookies and analytics

We may use cookies and similar technologies to:

• enable core Website functionality;
• understand Website usage and improve performance;
• measure marketing effectiveness.

You can control cookies through your browser settings and (if implemented) our cookie banner/preferences tool. Non-essential cookies should be used only with consent where required.

10) How long we keep data (retention)

We keep personal data only as long as necessary for the purposes described above, including:

• handling inquiries and valuations;
• performing and documenting mandates and transactions;
• meeting legal, accounting, and evidence obligations.

Retention periods may vary depending on the nature of the relationship and applicable legal requirements.

11) Data security

We use appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. No system is 100% secure; however, we continuously work to maintain an appropriate security level.

12) Your rights

Depending on applicable law (FADP and/or GDPR), you may have the right to:

• request access to your personal data;
• request correction of inaccurate data;
• request deletion (in certain cases);
• object to or restrict certain processing (where applicable);
• withdraw consent (where processing is based on consent);
• lodge a complaint with a competent authority.

Swiss data protection guidance and regulator examples reflect rights such as information/access, correction, and deletion.

13) Contact forms and communications

When you contact us, we process the data you provide to respond and to keep an internal record of communications. Please avoid sending sensitive personal data unless necessary.

14) Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The “Last updated” date indicates when it was most recently revised.